On 13 March 2024, the Brazilian IRS published Normative Instruction 2.180/24 (“IN 2.180/24”), which provides for the taxation of income earned by individuals resident in Brazil from non-interest-bearing deposits abroad, foreign currency held in kind, financial investments, controlled entities and trusts abroad, as well as the option to update the value of assets and rights abroad.
The long-awaited IN 2.180/24 regulates Law 14,754/23, which was passed on 12 December 2023 and brought important clarifications regarding the taxation by Income Tax of individuals (IRPF) with assets abroad.

On 27 March 2024, Decree No. 281/2024 (“Decree”) was published in the Official Gazette. The Decree extends the deadline for repatriating financial assets of at least 5% of the total value of assets located abroad from 31 March 2024 to 30 April 2024, inclusive.
As a reminder, the applicable personal assets tax rates for assets located abroad will be the same as those applicable to assets located in Argentina if, before 31 March of each year, taxpayers repatriate financial assets of at least 5% of the total value of assets located abroad and if certain additional requirements have been met.

On 19 March 2024, the Public Notice of Special Settlement Agreement No. 1/2024 was published, which provides for the opening of the Zero Litigation Program 2024, a new special settlement agreement for tax debts in administrative litigation within the scope of the IRS of Brazil, the value of which, per litigation, is up to BRL 50,000,000.00. Discounts and payment terms will be determined according to the degree of recoverability of the debts. The deadline for joining the Program is 1 April 2024 to 31 July 2024.

On 3 April 2024, the Federal Revenue of Brazil (RFB) issued Normative Instruction No. 2184/2024, which regulates the tax transaction provided in Article 14 of Law 14789/2023. This transaction aims to encourage companies to pay IRPJ and CSLL (corporate income taxes), resulting from the exclusion of investment subsidies made in disagreement with Article 30 of Law No. 12973 of 13 May 2014, provided that they have not been subject to assessment.